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On October 18, 2016, the Illinois Department of Healthcare and Family Services (“HFS”) issued a notice to school districts seeking Medicaid reimbursement for therapy services in IEPs.

HFS previously published a handbook for school districts and other LEA’s stating that OT, PT, and speech-language services in IEPs must be provided subject to a prescription or referral issued by a physician or “or other licensed practitioner of the healing arts acting within the scope of his or her practice under state law.” However, “other licensed practitioner of the healing arts” was never fully defined.

In the October 18, 2016, provider notice, HFS provided clarification on the definition by giving a list of examples of licensed practitioners of the healing arts, including: physician assistants, advanced practice nurses, clinical psychologists, speech-language pathologists, or individuals with a Professional Educator License (PEL) endorsed in School Psychology or Speech Language Pathology, subject to the provisions of the Illinois Health Care Worker and Self-Referral Act.

This clarification means that school districts may receive reimbursements for speech-language services referred by a speech-language pathologist and eliminates the need for a physician’s referral. The prescription/order or referral is required before services can begin and must be updated annually. The prescription/order is required to be kept in the student’s file and must be produced upon request of HFS. A signed IEP does not satisfy the requirement for a referral for services.

The provider notice also states that while OT and PT services must also be prescribed by a physician or other licensed practitioner of the healing arts, the state Physical Therapy Practice Act and Occupational Therapy Practice Act limits who can prescribe/order their respective services.

For more information, the provider notice is available here.

Medicaid reimbursement issues continue to arise in the wake of new federal mandates meant to curb Medicaid fraud. Contact Barbara Erickson or Pam Simaga with all of your Medicaid reimbursement inquiries.